Come Clean About Beauty 2

COME CLEAN ABOUT BEAUTY 2

Executive Summary

Greenwashing is rife in the health and beauty industry, despite previous Soil Association campaigns which have raised awareness of this problem amongst brands and consumers. Our new investigation has produced a league table of uncertified products which are using the term organic on the labels, and consumer research which provides clear evidence that people feel misled by this. We’re calling on brands to Come Clean About Beauty labelling and use the terms organic and natural responsibly or not at all.

We found a range of uncertified health and beauty products with potentially misleading labels which use the terms organic or natural. We showed some of these labels to an independent panel of 1,000 consumers and the majority (76%) said they felt misled when they found out the product was not certified and would not meet organic standards. When they discovered this, most people (72%) also said they would lose trust in the brand. Scope We have not been able to do a comprehensive survey of all beauty products, but our limited research found 13 products from eight different brands that have labels which could suggest to consumers that they are wholly or mainly organic, yet are not independently certified. Several of these products are from brands with one or more ranges which are all labelled in a way that consumers said they found misleading.

This means there are hundreds or even thousands of products for sale on UK high streets which make organic claims but contain ingredients which would not be permitted in a certified organic product. We are clear that risking misleading consumers in such a sensitive area as beauty products, even in one case, is completely unacceptable. The confusing terms on the labels we encountered suggest that it is often very difficult for consumers to know they are making the right choice when doing their shopping.

The halo effect Our research findings show a direct link between what is on the pack and what people say they think about a product. It is clear from the results of this survey that the use of the word organic on the label has a positive effect on what people think about the whole of the product – with most consumers saying they would assume an organic product was sus- tainably made and that they were doing the right thing for the environment by choosing it.

Some of the labels state that one or more ingredients are organic in a way which suggests positive attributes for the rest of the product. While it is obviously a good thing for a manufacturer to be using any organic ingredients, we do not think it is right for companies to highlight that particular organic ingredient on the front of the packaging when only a very small amount is actually present in the product.

The majority of people (77%) said they would feel reassured if the product was certified organic and carried a verified symbol. We think that brands know this, because a number of them use a logo of some form or another on their labels, to describe the presence of organic ingredients. Consumers also told us they would think more positively about the brand if the product was genuinely certified organic.

Brands and retailers should take note Consumers clearly told us that the misuse of the term organic damages their faith in brands and the retailers that sell them. Most people (72%) said they would lose trust in the brand if they found out that a product which said organic on the label was not certified and could not meet organic standards. 64% of people said they would lose trust in the retailer.

The majority of people (69%) also felt strongly that this sort of misleading labelling should be against the law. However the product labels and the ingredients they contain are all legal. While the term organic is regulated in relation to food and drink on sale in the UK and the EU, there is no legislation in place for the use of the terms organic and natural in relation to health and beauty products. We want to change this, so we are asking people to sign our petition which calls on the brands in our league table to truly Come Clean About Beauty and use the terms organic or natural responsibly or not at all. 4

Price is not an issue We found that certified organic products often cost less per 100ml than the uncertified products which are making organic and natural claims. For nine out of the 13 products included here we found a certified organic alternative which costs less per 100ml. Even for the four products where the organic alternative costs more, the difference in price is £1.50 per 100ml or less. By contrast, one of the uncertified products which claims to be organic costs £7.22 more per 100ml than a certified organic alternative.

In the Product Profiles section of this report, we suggest a certified organic alternative for each of the products featured. The basis of these suggestions is that the products are widely available in the UK at a competitive price and independently certified to a recognised standard. We are not saying these products contain similar ingredients or function in exactly the same way; they are simply suggestions of certified organic alternatives that consumers might like to consider.

Ingredients which would not be permitted in a certified organic product This report contains a snapshot of the products we found which contain ingredients that would not be permitted by an independent international organic and natural health and beauty standard such as COSMOS. When we had identified these ingredients, they were assessed by an independent expert toxicologist who advised us of their potential impacts in wider use on human health and the environment. Together we came up with the Terrible Ten – a list of ten ingredients which consumers should look out for – and which would never be permitted in a certified organic product.

There are European standards which require all ingredients used in cosmetic products to be safe, and limits for the amounts of some ingredients which can be used are set to ensure this. So we are not suggesting that the inclusion of any of these ingredients in the products listed means that those products are unsafe. We are talking about the impacts that some of these ingredients have been found to have in wider use – that is when used in higher doses and other product types or applications.

Organic standards aim to encourage the use of ingredients which are organic, sustainable and biodegradable, and most consumers said they felt misled when they found out that products which claim to be organic contained ingredients which would not be permitted in a certified product. This shows that the brands which are doing this are in danger of exploiting the reassurance that consumers seek when they choose an organic product. The majority of people (74%) told us they would feel like they were choosing a product which was free from nasties if it said organic on the label.

Consumers who want to protect themselves from greenwashing claims such as these should look for a genuine logo which proves the product has been independently certified. For example, the COSMOS or the Soil Association, Natrue and NSF-ANSI all have strict standards for beauty products, and would not allow a chemical on the Terrible Ten list to be used in a certified product. The Terrible Ten Our research found the following Terrible Ten ingredients in health and beauty products which mention organic on the label, but are not certified organic:

1. Ethyl hexylsalicylate 2. Homosalate 3. Imidazolidinyl urea 4. Octinoxate 5. Octocrylene 6. PEGs: PEG-7; PEG-12; PEG-40; PEG-200 7. Polyquaternium 7 8. Polysorbate 20 9. Red 17 artificial colour 26100 10. Retinyl palmitate

The ingredients are listed in alphabetical order. Further information on the possible effects of each of the ingredients, and the products in which we found them, is included in Section 4 of this report.

Research methodology We worked with an independent researcher to find health and beauty products which claim to be organic, but are not independently certified. We reviewed the ingredients panel for each product and identified whether there were any ingredients which would not be permitted in a certified organic product, using the international COSMOS standard as a benchmark. We then worked with a leading independent toxicologist, Emeritus Professor Vyvyan Howard, to identify the Terrible Ten ingredients found in these, and other non-organic products, which are chemicals that in general use are potentially most harmful to human health and the environment.

Following this we undertook some independent consumer research. The researchers spoke to 1000 women across the UK between the ages of 18-65, and a nationally representative sample of socio-demographic grades, employment status and regional representation. All participants were regular buyers and users of a wide range of everyday health and beauty products from body or face washes to after sun creams or sprays. The research was conducted online by market research and brand building company, The Crow Flies Ltd., between 31st March and 4th April 2017. 6

Contents

1. Come Clean About Beauty League Table: This shows the 13 uncertified health and beauty products we found which are labelled in ways that could mislead consumers, and contain undesirable ingredients, including those from the Terrible Ten.

2. Product profiles: Details of the products we found which we think are labelled in ways that could mislead consumers because they mention organic ingredients or use organic on their main labels, yet contain ingredients which would not be permitted in independently certified organic products.

3. Consumer research: An outline of the findings of the independent research undertaken as part of this campaign.

4. Terrible Ten Overview: A summary of each of these ingredients and the impacts they could have.

5. Terrible Ten datasheets: The scientific evidence provided by independent toxicologist Emeritus Professor Vyvy- an Howard. Brand Product Total Thumbs Terrible Ten ingredi- Comments score down ents /25

Boots Beautiful hair 19 • PEG-40 • The organic statement stands out on the front of the moisturise & • PEG-200 bottle but it only refers to one ingredient, the argan oil. nourish sham- • Polyquaternium-10 • Only a tiny amount of organic argan oil is actually in- poo with added • PEG-7 cluded in the product. organic argan oil • Polyquaternium-7 • The product contains five ingredients from the Terrible •+ 1 ingredient not permit- Ten and contains one additional ingredient that would ted in a certified organic not be permitted in a certified organic product. product. COOLA Makeup setting 14 • ethylhexyl methoxycin- • This product says ORGANIC SUNCARE prominently on spray Green Tea namate (octinoxate) the front. & Aloe • homosalate • It contains three ingredients from the Terrible Ten and • ethylhexyl salicylate (oc- four additional ingredients which would not be permit- tisalate) ted in a certified organic product. • + 4 ingredients not permitted in a certified organic product.

Aloe Organic Aloe 14 • Retinyl palmitate • The label states ORGANIC in large letters which sug- Pura Vera After Sun • + 5 ingredients not per- gests it applies to the whole product, not just the aloe Lotion mitted in a certified or- vera, which is the main ingredient. ganic product. • This product includes one ingredient from the Terrible Ten and five additional ingredients which would not be permitted in a certified organic product.

Rituals Heavenly Ham- 14 • ci 26100 (red 17) • The label states Organic Argan & Eucalyptus but these mam Organic • ethylhexyl salicylate are not major ingredients. Argan Oil and • + 6 ingredients not per- • This product contains two ingredients from the Terri- Eucalyptus revi- mitted in a certified or- ble Ten and six additional ingredients that would not be talising bath oil ganic product. permitted in a certified organic product. Brand Product Total Thumbs Terrible Ten ingredi- Comments score down ents /25

COOLA Pina Colada sun- 13 • ethylhexyl methoxycin- • This product makes two organic claims on the front of screen spray namate (octinoxate) the packaging: ORGANIC SUNCARE in a silver band and • ethylhexyl salicylate (oc- 70%+ organic ingredients. tisalate) • It contains three ingredients from the Terrible Ten and • octocrylene two additional ingredients which would not be permit- • + 2 ingredients not per- ted in a certified organic product. mitted in a certified organic product. Korres Basil lemon 11 • Imidazolidinyl urea • The label states ‘with organic althea extract’ and ’89.2% shower gel with • Polyquaternium-7 natural content’. organic althea • + 4 ingredients not per- • This product contains two of the Terrible Ten ingredi- extract mitted in a certified or- ents and four additional ingredients that would not be ganic product. permitted in a certified organic product.

Aloe Organic Aloe 11 • None, but contains 4 • The label states ORGANIC in large letters which sug- Pura Vera Gel which would not be per- gests it applies to the whole product, not just the aloe mitted in a certified or- vera, which is the main ingredient. ganic product. • This product does not include ingredients from the Terrible Ten but contains four ingredients which would not be permitted in a certified organic product. Korres Fig shower gel 10 • imidazolidinyl urea • The label states ‘with organic althea extract’ and ‘90.4% with organic • polyquaternium-7 natural content’. althea extract • + 3 ingredients not per- • This product contains two of the Terrible Ten ingredi- mitted in a certified or- ents and three additional ingredients that would not be ganic product. permitted in a certified organic product.

Dr Organic Moroc- 10 • None, but contains 2 • Organic appears prominently twice on the front of the Organic can Argan Oil which would not be per- packaging for this product. Shampoo mitted in a certified or- • This product does not include ingredients from the ganic product. Terrible Ten but contains two ingredients which would not be permitted in a certified organic product. Brand Product Total Thumbs Terrible Ten ingredi- Comments score down ents /25

Dr Organic Dead Sea 10 • None, but contains 2 • Organic appears prominently twice on the front of the Organic Mineral Night which would not be per- packaging but this product contains a large proportion Cream mitted in a certified or- of salt which cannot be certified organic. ganic product. • This product does not include ingredients from the Terrible Ten but contains two ingredients which would not be permitted in a certified organic product. Faith in Raspberry & 10 • Polysorbate 20 • The label states ‘With organic fruits’ but no further in- Nature cranberry shower • + 1 ingredient which formation is given about which fruit or how much. gel & bath foam would not be permitted in • Also includes a logo which shows ‘Certified Organic With Organic a certified organic prod- Ingredients’. Fruits uct. • The brand name and the term ‘Natural Skincare’ suggest the entire product is natural, but it contains an artificial ingredient which is also one of the Terrible Ten. • Also contains one additional ingredient which would not be permitted in a certified organic product. Faith in Pomegranate 9 • Polysorbate 20 • The label states ‘With Organic Pomegranate’ and in- Nature & rooibos hand • +1 ingredient which cludes a logo which shows ‘Certified Organic Ingredi- wash would not be permitted in ents’. With Organic a certified organic product • The brand name and the term ‘Natural Skincare’ could Pomegranate suggest the entire product is natural. • The product contains an artificial ingredient which is one of the Terrible Ten and one additional ingredient which would not be permitted in a certified organic product. The Sweet Vanilla Dry 9 • None, but contains 1 • ‘The Organic Pharmacy’ brand name could potentially Organic Oil which would not be per- mislead consumers because it suggests that the product Phar- mitted in a certified or- is organic. macy ganic product • This product does not include ingredients from the Terrible Ten but contains two ingredients which would not be permitted in a certified organic product. 10

Scoring methodology

Nasty ingredients – with a maximum score of 15: The presence of one of the Terrible Ten attracts a score of 2, with a maximum of 5 Terrible Ten ingredients appearing in any one of these products. Ingredients which would not be permitted in a certified organic product (using the international COSMOS standard as a baseline) attract a score of 1 point each in this category.

Prominence of claims – scored out of 5: The larger and more obvious the organic claim on the packaging, the higher the score. Products which make a claim about an ingredient only attract a lower score. If the product makes more than one claim, e.g. organic and natural, or the brand name includes the words natural or organic, it scores more highly. Products which include a logo which could potentially mislead consumers also score more highly.

Guidelines 5 points: Claims the whole product is organic very prominently on the front of the packaging, or in the brand name. Includes one or more logos which could lead consumers to believe the whole product is certified. 4 points: The organic and/or natural claims are prominent on the front of the packaging. May include a logo which could suggest to consumers that the product is certified. 3 points: The organic or natural claims may refer to one ingredient or the whole product but in our opinion, it is likely that consumers would believe they indicated the whole product is organic or may find them otherwise misleading. 2 points: Includes an organic claim which refers to one or more ingredient(s) but not the whole product. May not state which ingredients are organic or natural in the ingredients panel. 1 point: Organic claim is very small and/or only relates to one ingredient.

Availability of products score: the more widely available the products, the higher the number of consumers who could be misled. For this score we considered whether or not products are available on most UK high streets, or just in specialist outlets. Products which are available internationally also attracted a higher score.

Guidelines 5 points: products available in the world’s largest chain of chemists meaning they can be bought on the high street in most UK towns and cities 4 points: available on most UK high streets, or widely available internationally 3 points: available in larger stores in UK towns and cities and/or health food stores in most towns 2 points: available in some health food stores or only in capital cities and/or some international availability 1 point: only available online or in specialist shops. Product Profiles 12

Boots Beautiful Hair Moisturise & Nourish Shampoo with added Organic Argan Oil

What’s the problem? international COSMOS standard Argan oil is the 14th ingre- • In a certified organic product, Argania spinosa dient out of 16 listed in the (Kernel) oil would have to be organic and the product, so 13 ingredients percentage of organic ingredients would have are in the product in greater to be shown on the packaging. quantities, yet Boots are using • PEG-40, PEG-200, Polyquaternium-10, PEG-7, the fact that the argan oil is and Polyquaternium-7 are from the Terrible Ten organic to market the prod- and would not be permitted in a certified organ- uct using a star and stating ic or natural product. ‘Added ORGANIC ARGAN oil’ • Sodium laureth sulfate would not be permitted in large letters on the front of in a certified organic or natural product. the product. We think it could mislead consumers to use the Nasty ingredients score: 11/15 organic argan oil to sell the This product contains five ingredients from the product in this way, when the Terrible Ten list: PEG-40, PEG-200, Polyquater- shampoo obviously contains nium-10, PEG-7, and Polyquaternium-7. It also only a small amount (cos- contains one ingredient that would not be per- metics ingredients must be mitted in a certified COSMOS organic or natural listed in order of the amount product. included in the product).

This product contains five different nasty ingredients from the Terrible Ten list: PEG-40, PEG-200, Polyquaternium-10, PEG-7, and Polyquaterni- um-7. In wider use, these in- Prominence of gredients can cause allergies, claims score: 3/5 could damage your immune The organic claim is shown very prominently system, and may be toxic to on the front of the product. It refers to one the environment. ingredient but this ingredient is only present in a very small amount. What’s in it? Aqua (water), Sodium laureth sulfate, Cocami- Availability of products score: 5/5 dopropyl betaine, Sodium chloride, PEG-40 As the world’s largest chemist, Boots products hydrogenated castor oil, Panthenol, PEG-200 are very widely available in the UK and the US. hydrogenated glyceryl palmate, Sodium benzoate, Polyquaternium-10, Parfum (Fragrance), Total score: 19/25 Dipropylene glycol, Glyceryl laurate, PEG-7 glyceryl cocoate, Polyquaternium-7, Citric acid, How much does it cost? Normally retails at 72p Argania spinosa (Kernel) oil, Alpha-isomethyl per 100ml but currently on sale for 37p/100ml. ionone, Gerniol, Limonene, Linalool. What could you choose instead? Urtekram Nordic Birch shampoo for dry hair is £1.66/100ml, certified by Ecocert to the COSMOS organic standards. Our assessment of the ingredients against the COOLA Makeup Setting Spray Green Tea & Aloe

What’s the problem? Our assessment of the ingredients against the This product says OR- international COSMOS standard GANIC SUNCARE in a • In a certified organic product, Alcohol denat bright purple band across (SD alcohol 40-B) and alcohol would have to be the front of the box and in organic. capital letters on the prod- • Ethylhexyl methoxycinnamate, homosalate, uct itself, yet it contains ethylhexyl salicylate are from the Terrible Ten three ingredients from and would not be permitted in a certified organ- the Terrible Ten: ethyl- ic or natural product. hexyl methoxycinnamate • Four other ingredients: isodecyl neopen- (octinoxate), homosalate, tanoate, silica silylate, butyl methoxydibenzoyl- ethylhexyl salicylate (octi- methane and PVP would not be permitted in a salate). In wider use these certified organic or natural product. chemicals can disrupt hormones, cause allergies, Nasty ingredients score 10/15 affect the neurological de- Contains three ingredients from the Terrible velopment of babies and Ten: ethylhexyl methoxycinnamate (octinoxate), harm the environment. homosalate, ethylhexyl salicylate (octisalate) and four ingredients which would not be permitted There is also a logo on the in a certified organic product. bottle which states ‘made with CERTIFIED ORGANIC ingredients’ which could lead consumers to believe that the whole product is organic. Prominence of claims score 3/5 States ‘ORGANIC SUNCARE’ in a bright purple What’s in it? band across the front of the product and in- Alcohol denat (SD alcohol 40-B), citrus auran- cludes a logo which states ‘Made with CERTI- tium dulcis (orange) fruit extract, isodecyl ne- FIED ORGANIC ingredients.’ opentanoate, ethylhexyl methoxycinnamate, homosalate, silica silylate, ethylhexyl salicylate, Availability of products score 1/5 butyl methoxydibenzoylmethane, dicaprylyl Although this is a US brand, these products are carbonate, PVP, parfum/fragrance, aqua/water/ sold through British websites and may be avail- eau, glycerine, alcohol, algae extract, curcumis able in some larger high street stores. sativus (cucumber) fruit extract, , aloe barbadensis leaf juice, sodium hyaluronate, hydroxycit- Total score 14/25 ronelal, methyl 2-octynoate, limonene, amyl cinnamal, citronellol. How much does it cost? £72.00/100ml

What could you choose instead? There isn’t an organic alternative to makeup setting spray, but Skin & Tonic rose mist is £20/100ml, certified to Soil Association organic health and beauty standards and has been recommended for use over make up. 14

Aloe Pura Organic Aloe Vera After Sun Lotion

What’s the problem? Our assessment of the ingredients against the The label states ‘ORGAN- international COSMOS standard IC Aloe Vera’ in large • If this was a certified organic product, the Aloe letters but the ingredi- Barbadensis (Aloe Vera) Gel, Prunus amygdalus ents panel shows that dulcis oil, Sesamum indicum extract, Helianthus this product contains a annuus extract and Chamomilla recutita extract significant proportion would have to be organic. of retinyl palmitate, one • Retinyl palmitate is from the Terrible Ten and of the Terrible Ten in- would not be permitted in a certified organic or gredients. The label also natural product. includes a logo stating • Five other ingredients: Acrylates/C10-30 alkyl ‘made with organic aloe acrylate crosspolymer, Disodium EDTA, phe- vera’ which could lead noxyethanol, panthenol and hydrolysed colla- consumers to conclude gen would not be permitted in a certified organ- that the whole product is ic or natural product. organic. Nasty ingredients score 7/15 The label includes a Contains one ingredient from the Terrible Ten: panel stating ‘Natu- Retinyl palmitate. Also contains five ingredients ral Actives’ but retinyl which would not be permitted in a certified or- palmitate is an artificial ganic product. version of the naturally occurring retinyl, also known as vitamin A1. If our bodies absorb too much vitamin A (mainly from food) this can cause foetal deformation. In wider use, retinyl palmitate can be toxic to the environment and Prominence of claims score 4/5 only breaks down slowly in nature. States ORGANIC in large letters on the front and also includes a logo stating ‘made with organic What’s in it? aloe vera’ which could mislead consumers by Aloe Barbadensis (Aloe Vera) Gel, Dicaprylyl suggesting the whole product is organic. The la- ether, Tocopheryl acetate, Retinyl palmitate, bel includes a panel stating ‘Natural Actives’ but Citrus aurantium dulcis fruit extract, Panthenol, this product includes artificial ingredients. Hydrolyzed collagen, Prunus amygdalus dulcis oil, Persea gratissima extract, Sesamum indicum Availability of products score 3/5 extract, Helianthus annuus extract, Oryza sati- You can buy this in chemists and health food va extract, Hamamelis virginiana extract, Rosa stores on UK high streets centifolia extract, Vaccinium myrtillus extract, Melilotus officinalis extract, Malva sylvestris ex- Total score 14/25 tract, Chamomilla recutita extract, Tilia vulgaris extract, Lavandula hybrida extract, Eugenia car- How much does it cost? £3.25/100ml yophyllus extract, Citrus aurantifolia oil, Cym- bopogon schoenanthus oil, Litsea cubeba oil, What could you choose instead? Lecithin, Tocopherol, Ascorbyl palmitate, Citric Bentley Organic Sunsoothe After Sun Lotion acid, Acrylates/C10-30 alkyl acrylate crosspoly- is £1.94/100ml and certified to Soil Association mer, Disodium EDTA, Sodium hydroxide, Phe- organic health and beauty standards. noxyethanol, Potassium sorbate, Benzoic acid. Rituals Heavenly Hammam Organic Argan Oil and Eucalyptus Revitalising Bath Oil

What’s the problem? Our assessment of the ingredients against the The label states ‘Organic international COSMOS standard Argan Oil & Eucalyptus’ • In a certified organic product, sesamum indi- but this product contains cum (sesame) seed oil, argania spinosa (argan) two ingredients from the kernel oil and helianthus annuus (sunflower) Terrible Ten: ci 26100 seed oil would have to be organic. (red 17) and ethylhexyl • Ethylhexyl salicylate and ci 26100 (red 17) are salicylate. These ingredi- from the Terrible Ten and would not be permit- ents could have negative ted in a certified organic or natural product. impacts on the immune • Six ingredients: ci 47000 (yellow 11), ci 60725 system, cause allergies (violet 2), trilaureth-4-phosphate, laureth-4, and harm the environ- butylphenyl methylpropional and butyl meth- ment. oxydibenoylmethane would not be permitted in a certified organic or natural product. The eucalyptus and argan oil are the 11th Nasty ingredients score 10/15 and 12th ingredients out • Contains two ingredients from the Terrible of 28 in total, so there Ten: ci 26100 (red 17) and ethylhexyl salicylate. are 10 ingredients in • Contains six ingredients which would not be the product in greater permitted in a certified organic product. quantities, yet Rituals are using the fact that it Prominence of claims score 2/5 contains organic argan The claim is clearly visible in the middle of oil and eucalyptus oil to market the product by the packaging, but it only refers to two specific putting this claim on the front of the packaging. ingredients. We think it could mislead consumers to list just these ingredients on the front of the product in Availability of products score 2/5 this way. You can buy this in department stores on UK high streets. What’s in it? Ethylhexyl stearate, sesamum indicum (sesame) Total score 14/25 seed oil, caprylic/capric triglyceride, parfum/ fragrance, trilaureth-4 phosphate, laureth-4, How much does it cost? £13.50/100ml olus oil, aqua/water, tocopherol, calendula officinalis (calendula) flower extract, eucalyptus What could you choose instead? globulus (eucalyptus) leaf oil, argania spinosa Neal’s Yard Remedies Rose & Pomegranate or- (argan) kernel oil, helianthus annuus (sunflow- ganic Bath Oil is £15/100ml and certified to Soil er) seed oil, ethylhexyl methoxycinnamate, Association organic health and beauty stand- butyl methoxydibenzoylmethane, ethylhexyl ards. salicylate, hexyl cinnamal, citronellol, linalool, butylphenyl methylpropional, benzyl salicylate, geraniol, limonene, alpha-isomethyl ionone, cinnamyl alcohol, ci 26100 (red 17), ci 47000 (yellow 11), ci 60725 (violet 2). 16

COOLA Pina Colada Sunscreen Spray

What’s the problem? Our assessment of the ingredients against the This product says ORGANIC SUNCARE in a international COSMOS standard silver band on the front, states 70%+ certified • In a certified organic product, the alcohol organic ingredients and includes a logo which denat would have to be organic. says ‘made with CERTIFIED ORGANIC ingre- • Ethylhexyl methoxycinnamate, octocrylene, dients’, yet contains three ingredients from the ethylhexyl salicylate are from the Terrible Ten Terrible Ten: ethylhexyl methoxycinnamate and would not be permitted in a certified (octinoxate), ethylhexyl salicylate (octisalate) organic or natural product. and octocrylene. In wider use, these ingredients • Two ingredients; Butyl methoxydibenzoyl can disrupt hormones, cause allergies, affect the -methane and tetrasodium pyrophosphate neurological development of babies and harm would not be permitted in a certified COSMOS the environment. organic or natural product.

What’s in it? Nasty ingredients score 8/10 Alcohol denat, ethylhex- Contains three ingredients from the Terrible yl methoxycinnamate, Ten: ethylhexyl methoxycinnamate (octinox- octocrylene, ethylhexyl ate), ethylhexyl salicylate (octisalate) and oc- salicylate, butyl methoxy- tocrylene. It also contains two ingredients that dibenzoylmethane, methyl would not be permitted in a certified organic hydrogenated rosinate, and natural product. parfum, algin, arginine PCA, calcium sulfate, car- Prominence of claims score 4/5 ica papaya seed oil, rosa States ORGANIC SUNCARE in a silver band rubignosa seed oil, sodi- on the front and says 70%+ certified organic um phosphate, sodium ingredients. Includes a logo which states ‘Made diatomeae, tetrasodium with CERTIFIED ORGANIC ingredients.’ pyrophosphate, glycerine, aloe barbadensis leaf juice, Availability of products score 1/5 algae extract, curcumis Although this is a US brand, these products sativus fruit extract, fragar- are sold through British websites and may be ia vesca fruit extract, citric available in some larger high street stores. acid, potassium sorbate, sodium benzoate, Cl 15985 Total score 13/25

How much does it cost? £13.50/100ml

What could you choose instead? Neal’s Yard Remedies organic sun cream is £13.34/100ml and is certified by the Soil Association. Korres Basil Lemon Shower Gel with Organic althea extract

What’s the problem? Our assessment of the ingredients against the The label states ‘with international COSMOS standard organic althea ex- • Imidazolidinyl urea and polyquaternium-7 are tract’ and ’89.2% nat- from the Terrible Ten and would not be permit- ural content’ but this ted in a certified organic or natural product. product contains two • Four ingredients: Sodium laureth sulphate, of the Terrible Ten sodium cocoyl isethionate, butylphenyl methyl- nasty ingredients: propional and phenoxyethanol would not be al- imidazolidinyl urea lowed in certified organic and natural products. and polyquaternium-7. Polyquaterni- Nasty ingredients score 8/15 um-7 could be toxic Contains two of the Terrible Ten ingredients: to the environment. imidazolidinyl urea and polyquaternium-7. It The ingredients panel also contains four ingredients that would not does not show that the be permitted in certified organic and natural althaea root extract is products. organic. Prominence of claims score 1/5 This product also con- Claims are in small print and relate to one tains four ingredients ingredient plus a natural content percentage. which would not be permitted in a certi- Availability of products score 2/5 fied organic or natural You can buy these in larger UK high street stores product under the and they are available internationally. COSMOS standards. Total score: 11/25

What’s in it? How much does it cost? £3.20/100ml Water/eau, sodium laureth sulfate, cocamidopropyl betaine, sodium cocoyl isethionate, co- What could you choose instead? co-glucoside, glyceryl oleate, parfum/fragrance, Avalon organic lemon bath and shower gel is aloe barbadensis leaf juice, althaea officinalis currently on sale for £1.71/100ml, certified by root extract, arginine, benzyl alcohol, butylphe- NSF-ANSI to the American standard for nyl methylpropional, castoryl maleate, geran- personal care products which contain organic iol, guar hydroxypropyltrimonium chloride, ingredients. hydrolyzed wheat gluten, imidazolidinyl urea, lactic acid, limonene, linalool, phenoxyethanol, polyquaternium-7, potassium sorbate, sodium dehydroacetate, sodium gluconate, tocopherol. 18

Aloe Pura Organic Aloe Vera Gel

What’s the problem? Our assessment of the ingredients against the The label states ‘ORGANIC Aloe Vera’ in large international COSMOS standard letters but this product contains three • If this was a certified organic product, the Aloe ingredients which would not be permitted in barbadensis (Aloe Vera) Leaf Juice would have a certified organic product: Acrylates/C10-30 to be organic. Alkyl Acrylate Crosspolymer, Panthenol • Four ingredients; Acrylates/C10-30 Alkyl (Pro-vitamin B5), Disodium EDTA (none of Acrylate Crosspolymer, Panthenol (Pro-vitamin these ingredients are listed in the Terrible Ten). B5), Disodium EDTA and phenoxyethanol would not be permitted in a certified organic or natural What’s in it? product. Aloe barbadensis (Aloe Vera) Leaf Juice (Organ- ic), Acrylates/C10-30 Alkyl Acrylate Crosspol- Nasty ingredients score 4/15 ymer, Panthenol (Pro-vitamin B5), Disodium Does not contain any ingredients from the EDTA, Sodium Hydroxide, Phenoxyethanol, Terrible Ten but does contain four ingredients Potassium Sorbate, Benzoic Acid. which would not be permitted in a certified organic product: acrylates/C10-30 Alkyl Acrylate Crosspolymer, Panthenol (Pro-vitamin B5), Disodium EDTA and phenoxyethanol.

Prominence of claims score 4/5 States ORGANIC in large letters on the front and also includes a logo stating ‘made with organic aloe vera’ which could mislead consumers by suggesting the whole product is organic. The label includes a panel stating ‘Natural Actives’ but this product contains artificial ingredients.

Availability of products score 3/5 You can buy this in chemists and health food stores on UK high streets

Total score 11/25

How much does it cost? £2.34/100ml

What could you choose instead? Urtekram aloe vera body lotion is £1.70/100ml and certified to COSMOS organic by Ecocert. Korres Fig Shower Gel with Organic Extracts of Althea & Helichrysum

What’s the problem? Our assessment of the ingredients against the The label states ‘with international COSMOS standard organic althea ex- • Imidazolidinyl urea and polyquaternium-7 are tract’ and ’90.4% nat- from the Terrible Ten and would not be permit- ural content’ but this ted in a certified organic or natural product. product contains two • Three ingredients: Sodium laureth sulphate, of the Terrible Ten Sodium cocoyl isethionate and phenoxyethanol nasty ingredients: im- are not permitted in certified organic and natu- idazolidinyl urea and ral products polyquaternium-7. The ingredients panel Nasty ingredients score 7/15 does not show that the Contains two of the Terrible Ten ingredients: althaea root extract is imidazolidinyl urea and polyquaternium-7. It organic. also contains three ingredients that are not permitted in certified organic and natural products. This product also contains three ingredients which would not be permitted in a certified organic or natural product under the COSMOS standards.

Prominence of claims score 1/5 Claims are in small print and relate to one ingredient plus a natural percentage What’s in it? Aqua/water/eau, sodium laureth sulfate, co- Availability of products score 2/5 camidopropyl betaine, sodium cocoyl isethion- You can buy these in larger UK high street stores ate, cocoglucoside, glyceryl oleate, parfum/ and they are available internationally. fragrance, aloe barbadensis leaf juice, althaea officinalis root extract, arginine, benzyl alcohol, Total score: 10/25 castoryl maleate, guar hydroxypropyltrimonium chloride, hydrolyzed wheat gluten, imidazolidi- How much does it cost? £3.20/100ml nyl urea, lactic acid, linalool, phenoxyethanol, polyquaternium-7, potassium sorbate, sodium What could you choose instead? dehydroacetate, sodium gluconate, tocopherol. Avalon organic rosemary bath and shower gel is currently on sale for £2.00/100ml, certified to the American standard for personal care products which contain organic ingredients by NSF-ANSI. 20

Dr Organic Organic Moroccan Argan Oil Shampoo

What’s the problem? Our assessment of the ingredients against the Organic appears international COSMOS standard prominently twice • In a certified organic product, Argania spinosa on the front of the (Argan) oil and Citrus Limon peel oil would have packaging for this to be organic. product, but it is not • Two ingredients; Sodium hydroxymethylglyci- certified organic and nate and palmitamidopropyltrimonium chloride we think this could would not be permitted in a certified organic or mislead consumers. natural product.

It contains two Nasty ingredients score 2/15 ingredients which Does not contain ingredients from the Terrible are not permitted in Ten but does contain two ingredients that are products which are not permitted in products which are certified to certified to inde- independent organic standards. pendent organic standards such as COSMOS.

What’s in it? Aloe barbadensis leaf juice, Aqua, Cocami- dopropyl betaine, Sodium cocoam- phoacetate, Sodium lauroyl sarcosinate, Prominence of claims score 5/5 Coco glucoside, The brand name could mislead consumers Glyceryl oleate, Palmitamidopropyltrimonium because it suggests that the product is organic. chloride, Glycerin, Caprylyl/Capryl glucoside, The product label also says that it is organic. Argania spinosa (Argan) oil, Citrus aurantium dulcis, Eugenia caryophyllus (Clove) leaf oil, Availability of products score 3/5 Pelargonium graveolens (Geranium) oil, Citrus These products are widely available in health limon peel oil, Pogostemon cablin (Patchouli) food stores on UK high streets. oil, Cinnamomum zeylanicum (Cinnamon) leaf oil, Aniba rosaeodora (Rosewood) oil, Mentha Total score 10/25 arvensis herb oil, Citrus nobilis (Mandarin) peel oil, Vanilla planifolia (Vanilla) fruit extract, Men- How much does it cost? £2.37/100ml tha spicata herb oil, Kigelia Africana fruit extract, Hibiscus sabdariffa flower extract, Adansonia What could you choose instead? digitata fruit extract, Sorbitan sesquicaprylate, Avalon Organic lavender shampoo is Sodium hydroxymethylglycinate, Sodium ben- £1.85/100ml and certified to the American zoate, Potassium sorbate, Benzyl alcohol, Dehy- National Standard for Organic Personal Care droacetic acid, Citric acid, Limonene, Eugenol, Products by NSF-ANSI. Linalool. Dr Organic Organic Dead Sea Mineral Night Cream

What’s the problem? Organic appears prominently twice on the front of the packaging for this product, but it is not certified organic and we think this could mislead consumers.

• This product contains two ingredients which would not be permitted in a certified organic or natural product. • Maris sal (Dead Sea salt) is the 11th ingredient out of 61 in total, which suggests it is present in the product in a fairly large quantity. As sea Our assessment of the ingredients against the salt is not an agricultural product it cannot be international COSMOS standard organic and we think it is therefore potentially • In a certified organic product Theobroma misleading because the packaging suggests that cacao (Cocoa) butter, Butyrospermum parkii this entire product is organic. (Shea) butter, Simmondsia chinensis (Jojoba) seed oil, Prunus armeniaca (Apricot) kernel oil, What’s in it? Prunus amygdalus dulcis (Sweet almond) oil, Aloe barbadensis leaf juice, Aqua, Cetearyl alcohol, Helianthus annuus (Sunflower) seed oil and Glycerin, Glyceryl stearate citrate, Isoamyl laurate, Chamomilla recutita extract would have to be Theobroma cacao (Cocoa) butter, Butyrospermum organic. parkii (Shea) butter, Simmondsia chinensis (Jojoba) seed oil, Brassica campestris (Rapeseed) sterols, Maris • Two ingredients, urea and panthenol, would sal (Dead Sea salt), Sodium hyaluronate, Vitis vinif- not be permitted in a certified organic or natural era (Grape) seed oil, Pomegranate seed oil, Linum product. usitatissimum (Linseed) seed oil, Prunus armeniaca (Apricot) kernel oil, Persea gratissima (Avocado) oil, Nasty ingredients score 2/15 Prunus amygdalus dulcis (Sweet almond) oil, Hydro- Contains two ingredients that are not permitted genated vegetable oil, Glyceryl caprylate, Plantago in products which are certified to independent lanceolata (Plantain) leaf extract, Artemisia umbell- organic standards such as COSMOS. iformis extract, Buddleja davidii (Butterfly bush) extract, Tocopherol, Helianthus annuus (Sunflower) Prominence of claims score 5/5 seed oil, Chondrus crispus extract, Xanthan gum, Chamomilla recutita extract, Tilia cordata (Linden The brand name could mislead consumers flower) extract, Achillea millefolium (Yarrow) extract, because it suggests that the product is organic. Melilotus officinalis (Sweet clover) extract, Altaea The product label also says that it is organic. officinalis (Marshmallow) extract, Malva sylvestris leaf (Mallow) extract, Glucose, Sorbitol, Sodium Availability of products score 3/5 glutamate, Urea, Sodium PCA, Glycine, Lactic acid, These products are widely available in health Hydrolyzed wheat protein, Panthenol, Ascophyllum food stores on UK high streets. nodosum extract, Fucus vesiculosus (Bladderwrack) extract, Laminaria digitata extract, Citric acid, Ascor- bic acid, Citrus aurantium amara (Bitter orange) leaf Total score 10/25 oil, Citrus aurantium dulcis (Orange), Citrus nobilis (Mandarin) peel oil, Pinus sylvestris (Pine) needle How much does it cost? £18.58/100ml oil, Thymus vulgaris (Thyme) flower/leaf oil, Mentha arvensis (Wild mint) herb oil, Mentha spicata (Spear- What could you choose instead? mint) herb oil, Sodium phytate, Sodium benzoate, Lavera re-energising sleeping cream is Potassium sorbate, Citral, d-Limonene, Geraniol, £17.78/100ml and is certified organic by Natrue. Linalool. 22

Faith in Nature Raspberry & Cranberry Shower Gel & Foam Bath

What’s the problem? Our assessment of the ingredients against the The label states ‘With international COSMOS standard Organic Fruits Nat- • In a certified organic product, Helianthus ann- ural Skin Care’ but uus seed oil would have to be organic. this product includes • Polysorbate 20 is from the Terrible Ten and one ingredient from would not be permitted in a certified organic or the Terrible Ten plus natural product. one other ingredient • One ingredient; Ammonium laureth sulfate which would not be would not be permitted in a certified organic or permitted in a certi- natural product. fied natural or organic product. Nasty ingredients score 3/15 Contains one ingredient from the Terrible Ten: • The Terrible Ten Polysorbate 20, and one ingredient that would ingredient Polysorb- not be permitted in a certified organic and ate 20 is artificial and natural product. in wider use has been shown to cause serious eye irritation and allergic skin reactions. • Although the ingredients panel shows that it contains or- Prominence of claims score 3/5 ganic raspberry and • We think the brand name and the term cranberry fruit ex- ‘Natural Skincare’ suggest the entire product (or tract, it also contains even the entire product range) is natural, but it non-organic blueber- contains an artificial ingredient. ry extract. • We believe the use of the logo which shows • The front of the ‘Certified Organic Ingredients’ could be packaging includes a misleading because people may think this logo which states ‘Certified Organic Ingredients’ means all of the ingredients are organic. without any qualifications, but according to • We believe the claim ‘With Organic Fruits’ is the ingredients panel, only three of the 17 total slightly misleading because not all of the fruit ingredients are organic. ingredients in this product are organic.

What’s in it? Availability of products score 4/5 Ammonium laureth sulfate*, Maris sal, Cocami- You can buy these products in many stores on dopropyl betaine*, Polysorbate 20*, Glycerin*, most UK high streets as well as health food Rubus idaeus fruit extract**, Vaccinium macro- shops. carpon fruit extract**, Vaccinium angustifolium fruit extract*, Tocopherol*, Helianthus annuus Total score 10/25 seed oil*, Alcohol denat**, Parfum*, Citric acid*, Sodium benzoate, Potassium sorbate, Anthocy- How much does it cost? £1.11/100ml anins*, Beta vulgaris* *Vegetable derived What could you choose instead? **Organic certified Bentley Organic Skin Blossom bath soak is £1.76/100ml and is certified to Soil Association organic health and beauty standards. Faith in Nature Pomegranate & Rooibos Hand Wash

What’s the problem? Our assessment of the ingredients against the The label states ‘With international COSMOS standard Organic Pomegran- • Polysorbate 20 is from the Terrible Ten and ate’ and ‘Natural Skin would not be permitted in a certified organic or Care’ but this product natural product. contains Polysorbate • One ingredient: Ammonium laureth sulfate 20, which is artificial would not be permitted in a certified organic or and has been shown in natural product. wider use to cause serious eye irritation and Nasty ingredients score 3/15 allergic skin reactions. Contains one ingredient from the Terrible Ten: • It also contains an- Polysorbate 20 and one ingredient that would other ingredient which not be permitted in a certified organic and would not be permit- natural product. ted in a certified natural or organic product. • The front of the packaging also includes a logo which states ‘Certified Or- ganic Ingredients’ without qualification, but according to the ingredients panel, only three of the 17 ingredi- Prominence of claims score 2/5 ents are organic: pomegranate extract, rooibos • We think the brand name and the term extract and alcohol. ‘Natural Skincare’ suggest the entire product • The brand name and the strapline ‘natural (or even the entire product range) is natural, but skincare’ also suggest that the ingredients are it contains an artificial ingredient. natural but polysorbate 20 is an artificial ingre- • We believe the use of the logo which shows dient. ‘Certified Organic Ingredients’ could be misleading because people may think this What’s in it? means all of the ingredients are organic. Aqua, Ammonium laureth sulfate*, Maris sal, Polysorbate 20*, Cocamidopropyl betaine*, Pu- Availability of products score 4/5 nica granatum fruit extract**, Aspalathus line- You can buy these products in many stores aris leaf extract***, Glycerin*, Alcohol denat**, on most UK high streets as well as health food Melaleuca alternifolia leaf oil*, Anthocyanins*, shops. Sodium benzoate, Potassium sorbate, Citric acid*, Aroma*, Linaloolº, Limoneneº Total score 9/25 * Vegetable derived ** Organic certified & ethically traded º from essential oils (fragrance) allergens. How much does it cost? £1.15/100ml

What could you choose instead? Bentley Organic Cleansing Hand wash is £1.40/100ml and is certified to Soil Association organic health and beauty standards. 24

The Organic Pharmacy Sweet Vanilla Dry Oil

What’s the problem? Our assessment of the ingredients against the ‘The Organic Pharma- international COSMOS standard cy’ brand name could • In a certified organic product, Alcohol, mislead consumers Simmondsia Chinesis (Jojoba) seed oil, Argania because it suggests that Spinosa Kernal Oil, Helianthus Annuus (Sun- the product is organic, flower) Seed Oil and Olea Europaea (Olive) Fruit but this product con- Oil would have to be organic. tains two ingredients • Two ingredients; Hydroxyisohexyl 3- which are not permitted Cyclohexene Carboxaldehyde and diheptyl in products which are succinate would not be permitted in a certified certified to independent organic or natural product. organic standards such as COSMOS. Nasty ingredients score 2/15 Does not contain ingredients from the Terrible What’s in it? Ten but does contain two ingredients which Diheptyl Succinate, would not be permitted in a certified organic Capryloyl Glycerin/ product. Sebacic Acid Copolymer, Alcohol, Simmondsia Prominence of claims score 5/5 Chinesis (Jojoba) seed The brand name ‘The Organic Pharmacy’ oil, Argania Spino- suggest that this product is organic. This is sa Kernal Oil , Parfum reinforced by a promise on the side of the box (Fragrance), Helianthus which states ‘the first pharmacy dedicated to all Annuus (Sunflower) things organic.’ On the back of the box it states Seed Oil, Olea Europaea that this product is made with 99% Natural (Olive) Fruit Oil, Calen- ingredients. The ingredients panel does not dula Officinalis Flower differentiate between natural and organic Extract, Hypericum ingredients. Perforatum Extract, Rosa Canina Fruit Oil , Vanilla, Hydroxyisohexyl 3-Cyclohexene Availability of products score 2/5 Carboxaldehyde You can buy these products online and from 13 stores in the UK, most of which are in London. Available in stores in over 30 c ountries worldwide.

Total score 9/25

How much does it cost? £35/100ml

What could you choose instead? Herbfarmacy enriching body oil is £27.78/100ml and certified to Soil Association organic health and beauty standards. 3. Consumer research

We wanted to find out whether consumers Other key findings from our research shared our concerns about the use of the word organic on product labels. We asked independ- 74% of people said that by choosing a prod- ent market research and brand building com- uct which says organic on the label, they’d pany, The Crow Flies to carry out some research feel like they were using a product free from for us, which took place between 31st March nasties. and 4th April 2017. • Yet nine of the products in our league table contain ingredients from the Terrible The researchers spoke to 1000 women across Ten, which have been shown to be harmful to the UK between the ages of 18-65, which made human health and the environment in wider up a nationally representative sample of so- use, and the rest contain other ingredients that cio-demographic grades, employment status would not be allowed in certified organic and regional representation. All participants products. were regular buyers and users of a wide range of everyday health and beauty products from body 64% of people said they’d feel like they were or face washes to after sun creams or sprays. getting less value for money when they found The research was conducted online. out the products weren’t certified organic, despite saying organic on the label. We showed consumers the labels of five of the • But our research has shown that you could products from our Come Clean About Beauty actually buy a certified organic product for less league table, which have ‘organic’ featured in than the cost of a misleadingly labelled product various levels of prominence, all with a slight in most cases. change to the brand name. Significant propor- tions of people picked up on organic as a nota- Trust ble feature unprompted. • 72% of people said they’d lose trust in the brand when they found out the product could People also told us that they think ‘organic’ not meet organic standards. conveys multiple positive benefits, particularly • Most people (69%) thought it should be against that it is better for their health and the environ- the law to make organic claims on products ment. When the possibility that the products which are not certified. are not certified organic and could not meet organic standards was raised, the response was Positive association with organic unequivocal: 76% of consumers strongly agreed • 77% of people said they’d feel reassured if or agreed that they would feel misled (only 8% the product was certified organic. disagreed). • 75% of people said they’d think more positively about the brand if the product Genuine organic accreditation was seen as was certified organic. extremely positive with 77% strongly agreeing or agreeing that they would be reassured by it. 69% Retailers of people said they would feel they were doing • 64% of people said they’d lose trust in the re- the right thing or making a positive choice by tailer when they found out that beauty products choosing a certified organic product. Most peo- which say organic on the label are not certified ple (70%) said that organic certification would and could not meet organic standards. make them think positively about the brand • 68% of people said they’d think more and 68% of consumers said it would make them positively about the retailer if the product think positively about the retailer. was certified organic. 26

4. Summary of the possible impacts of the Terrible Ten

We are not suggesting that the inclusion of any of these ingredients in the products listed means that they are not safe for use in the products where we found them. However, we do think it could be misleading to include these ingredients in products which claim to be organic, when they would not be permitted in an organically certified product, and we do not think consumers would expect to find ingredients like these in products that they believe are either organic or natural. The side effects listed below have been identified in wider research of the possible impact of these chemicals on human health and the environment. (See Terrible Ten data sheets in Section 5 below for more details and full references.) 1 - Ethyl hexylsalicylate (Octisalate)

What is it used for? Used as a chemical UV filter in sunscreen, a fragrance ingredient and to help the skin better absorb cosmetics.

Features: Made from sacylic acid and ethanol.

Side effects: • May have negative impacts on the immune system. • Potential to cause allergies including acute contact dermatitis. • Eco-toxicity – concerns that it damages the environment.

Summary of our findings: Also found in hair dye, this ingredient is used in sunscreen to help easy absorption and promote longer lasting sun protection. However, in wider use it may have a negative impact on the immune system, and has the potential to cause acute contact dermatitis or other allergies. It may also be toxic to the environment. Regulations restrict the amount of octisalate that can be used in beauty products – but with safe alternatives to octisalate available, you don’t have to take that risk.

Where we found it: • Rituals Heavenly Hammam Organic Argan Oil and Eucalyptus bath oil • COOLA ORGANIC SUNCARE Sport sunscreen spray Pina Colada SPF30 (listed as octisalate) • COOLA ORGANIC SUNCARE Makeup setting spray (listed as octisalate) 28

2 – Homosalate

What is it used for? Chemical sunscreen which offers protection from UVB but not UVA. It is aromatic and also acts as a skin conditioner.

Features: Artificially produced chemical

Side effects: • May cause allergies. • Shown to be estrogenic which means it disrupts our hormones and may block male hormones. • Has been found in human breast milk. • Could be contaminated with salicylic acid which has been associated with harming the development of babies.

Summary of our findings: Like many of the Terrible Ten ingredients, homosalate is used in sunscreens to offer protection from UVB rays, and as a skin conditioner. UVB blocking prevents sunburn which warns us when we’ve had too much sun, so the use of homosalate means we can risk overexposing our skin to the sun’s harmful rays. This ingredient may also cause allergies. Worryingly, in wider use it is shown to have harmful effects on hormones – it may stop male hormones from working. In wider use it is also known to be at risk of being contaminated with a chemical associated with harming foetal development. It has also been found in human breast milk.

Where we found it: • COOLA ORGANIC SUNCARE Makeup setting spray 3 - Imidazolidinyl urea

What is it used for? Helps to retain moisture in the upper layers of the skin

Features: Artificial antimicrobial preservative also used in insect repellent

Side effects: • May release formaldehyde – a class one carcinogen, which also causes allergic reactions.

Summary of our findings: Imidazolidinyl urea is used in beauty products to help retain moisture – you may find it in deodorant, hand cream and shampoo. It’s a man-made chemical formed from three ingredients: formaldehyde, caustic soda and hydrochloric acid. Imidazolidinyl urea may release formaldehyde, which may cause cancer in humans and may also damage your DNA. You may also find imidazolidinyl urea in ointment for aching joints.

Where we found it: • Korres Fig shower gel with organic extracts of althaea & helichrysum • Korres Basil lemon shower gel with organic extracts of althaea & helichrysum 30

4 - Octinoxate

What is it used for? Found in sunscreens, it blocks UVB rays.

Features: Antimicrobial ingredient, also found in insect repellent.

Side effects: • Hormone disrupter in animals. Potentially hormone disrupting in humans. • Bioaccumulates within our bodies, which can’t get rid of it naturally. • Could affect the neurological development of babies.

Summary of our findings: An ingredient also found in insect repellent, octinoxate is used in sun creams to block the sun’s harmful UVB rays. But it has been found to act as an endocrine disruptor in animals, meaning that it could potentially change the natural function of our hormones. It could also affect neurological development in babies, and bio-accumulates in humans – meaning once we put it on, it sticks around as our bodies can’t get rid of it.

Where we found it: • COOLA ORGANIC SUNCARE Sport sunscreen spray Pina Colada SPF30 (listed as octisalate) • COOLA ORGANIC SUNCARE Makeup setting spray (listed as octisalate) 5 - Octocrylene

What is it used for? Chemical sunscreen filter blocks UVB and some UVA rays.

Features: UV absorber suspected to be persistent.

Side Effects: • Skin irritant which is suspected to be persistent. • Strong allergen which can cause contact dermatitis in children. • Photo contact allergies – meaning it causes allergies when it is exposed to sunlight.

Summary of our findings: Octocrylene is a UV absorber, stopping the sun’s harmful rays from getting through to your skin. However, it can cause strong allergies and dermatitis in children and adults. It is suspected to be persistent, and has been found in people and animals alike. Bizarrely, octocrylene has been shown to actually cause allergies when it is exposed to sunlight.

The future isn’t so bright for octocrylene, which has been deemed so potentially harmful that it may be phased out in the coming years. For now, it’s still found in a variety of sunscreen brands – including those making claims that may make consumers think they are organic.

Where we found it: • COOLA ORGANIC SUNCARE Sport sunscreen spray Pina Colada SPF30 (listed as octisalate). 32

6 - PEGs: PEG-7; PEG-40; PEG-200; PEG-12

What is it used for? Used to thicken products to improve texture, carry moisturisers or as solvents in the manufacturing of products.

Features: Also used in pharmaceuticals as laxatives and in industrial manufacturing, PEGs are derived from petrochemicals.

Side effects: • If there is no guarantee of purity the product may contain contaminants ethylene oxide and 1,4 dioxane, which both cause cancer.

Summary of our findings: PEGs are man-made ingredients made from petrochemicals that thicken products and have moisturising properties, so they’re often found in moisturisers, shampoo and sur- prisingly, laxatives. Unlike the other ingredients on our Terrible Ten list, PEGs are relatively safe – providing they are pure, but in wider use PEGs can contain contaminants like ethylene oxide, which has been classed as a definite human carcinogen.

Where we found it: • Boots Beautiful Hair moisturise & nourish shampoo with added organic argan oil. 7 - Polyquaternium 7

What is it used for? An anti-static agent, it is used in shampoo and conditioner to stop hair looking frizzy.

Features: Artificial polymer

Side Effects: • Could be contaminated with acrylamide, a possible cancer-causing chemical. • Concerns have been raised that it is toxic to the environment.

Summary of our findings: Polyquaternium 7 is an anti-static agent typically found in shampoos and conditioners. In wider use, if it is contaminated with acrylamide, this is a potentially cancer-causing chemical, and could be toxic to the environment.t

Where we found it: • Boots Beautiful Hair moisturise & nourish shampoo with added organic argan oil • Korres Basil lemon shower gel with organic extracts of althaea & helichrysum • Korres Fig shower gel with organic extracts of althaea & helichrysum 34

8 - Polysorbate 20

What is it used for? This is a detergent used to clean things and an emulsifier which is used to mix oil and water. It’s found in bubble bath, body wash, shampoo & hand wash.

Features: a detergent found in cleaning products including this flea comb.

Side effects: • Has been associated with serious eye irritation. • Can cause allergic skin reactions. • Can be contaminated with cancer-causing chemicals during the manufacturing process.

Summary of our findings: Polysorbate 20 acts as a detergent and is used in body wash, shampoo and other products that cleanse and clean. It has been associated with serious eye irritation – polysorbate 20 is also an ingredient used in flea treatments. In wider use, this ingredient could be contaminated with cancer-causing chemicals, and there are concerns that it can cause allergic reactions on your skin.

Where we found it: • Faith in Nature Raspberry & cranberry shower gel & bath foam • Faith in Nature pomegranate & rooibos hand wash 9 - Red 17 artificial colour 26100

What is it used for? This artificial dye is used to create a red colour in cosmetic products. We found it in bath oil but it has also been used in red beauty products such as blusher or lipstick.

Features: An artificial chemical from the diazo dye family, red 17 is highly soluble in fats.

Side effects: • Persistent in wildlife, the body cannot get rid of it naturally. • Toxic to our organs – harmful to your liver and kidneys. • Evidence to suggest it might cause cancer (gaps in data about its safety).

Summary of our findings: Artificial colour 26100 (aka Red 17) is a dye that gives products a deep crimson shade not found in nature. It can be found in blusher, lipsticks and bath oils. There’s a lot we don’t know about this ingredient, which is also found in hair bleach and nail polish in the US, where we know product regulations are much weaker than those in Europe.

Evidence suggests it could be toxic to our organs in wider use and it may cause cancer in humans. We also know Red 17 is biopersistent, which means it accumulates in wildlife because it can’t be broken down naturally. The European Commission even declared that Red 17 should be banned in cosmetics because of safety concerns. But no one really knows the full impacts of this potential toxin because there are data gaps that prevent scientists from performing an adequate risk assessment.

Where we found it: • Rituals Heavenly Hammam Organic Argan Oil and Eucalyptus bath oil 36

10 - Retinyl palmitate

What is it used for? An anti-oxidant, retinyl is otherwise known as vitamin A1. Retinyl occurs naturally in foods but retinyl palmitate is artificial. It is used in anti-aging products and sunscreens.

Features: Although retinyl is produced naturally in our bodies, retinyl palmitate is the artificial version sometimes added to beauty products.

Side effects: • The use of retinyl palmitate can lead to too much vitamin A in our bodies. The biggest risk related to this is to the unborn children of pregnant women, who could suffer foetal malformations. • Persists in the environment as it cannot be broken down in nature. • Can be toxic to the environment.

Summary of our findings: Retinyl is a form of Vitamin A which is produced naturally in our skin, where it protects against ageing. However, retinyl palmitate is artificially produced and added to body lo- tions and after sun creams. Using these could lead to too much vitamin A in the body.

Too much Vitamin A can lead to developmental toxicity, or foetal malformations in babies in the womb. There is evidence to suggest that applying a product with retinyl palmate to your whole body could exceed the recommended daily dose of Vitamin A.

Where we found it: • Aloe Pura Organic Aloe Vera After Sun Lotion 5. Terrible Ten datasheets

1. Ethylhexyl salicylate (Octisalate)

What is it? This is a chemical ester formed by the condensation of salicylic acid with 2-ethylhexanol.

What is it used for? The salicylate portion of the molecule acts as a filter to ultraviolet B radiation. The 2-ethy- hexanol portion is a fatty alcohol and has oil-like emollient properties. Ethylhexyl salicilate is used in sunscreens as a UV filter. It enhances skin penetration of cosmetics.

Where does it come from? A carbon-based compound synthesised chemically.

What are the health/environmental concerns? The main concern from a human health perspective for Octisalate is the possible effects on the human immune system and allergenicity. Singh and Beck1 describe acute contact dermatitis caused by octisalate and Shaw2 presents a case study on a patient where patch testing demonstrated contact sensitivity to octisalate.

1 Singh M, Beck MH. 2007. Octyl salicylate: a new contact sensitivity. Contact Dermatitis 56(1): 48. 2 Shaw DW. 2006. Allergic contact dermatitis from octisalate and cis-3-hexenyl salicylate. Dermatitis 17(3): 152-155. 38

2. Homosalate

What is it? It is an ester formed from salicylic acid and 3,3,5-trimethylcyclohexanol.

What is it used for? A chemical barrier filter to ultraviolet radiation. Widely used sun screen agent. Also acts as a skin conditioner.

Where does it come from? Synthetic carbon-based chemical

What are the health/environmental concerns? This aromatic compound has a number of question marks over it. This includes suspected allergenicity, and low level endocrine disruption.

Homosalate is a chemical barrier and is in widespread use. While it offers some protection from UVB it is not an efficient barrier to UVA. The UVB blocking prevents sunburn which is the warning sign of over exposure so there is a risk that overexposure to UVA can occur. Homosalate has been found in human breast milk. As with octisalate, homosalate can be contaminated with salicylic acid, which has been associated with possible developmental toxicity.

The review of sunscreens and their adverse effects by Krauss et al (2012) quotes Schreurs et al (2005)3 and reveals that homosalate has been shown to possess endocrine disrupting properties in vitro. Other sunscreens reviewed in the Krauss et al paper also demonstrated in vivo effects in addition and were of high concern. Homosalate was designated of mod- erate concern. It has been shown to have estrogenic activity, possibly through acting as an anti-androgen.

However the lack of in vivo evidence of toxicity with homosalate should not remove the need for precaution given the fact that it has been found in human breast milk.

3 Schreurs RH, Sonneveld E, Jansen JH, Seinen W, van der Burg B (February 2005). “Interaction of polycyclic musks and UV filters with the estrogen receptor (ER), androgen receptor (AR), and progesterone receptor (PR) in reporter gene bioassays”. Toxicol. Sci. 83: 264–72. 3. Imidazolidinyl urea

What is it? A chemical antimicrobial which also helps to retain moisture in the upper layers of the skin. It is found in a wide variety of cosmetic products.

What is it used for? An antimicrobial with a mode of action involving the release of formaldehyde, which is a Class 1 human carcinogen (IARC). Hence concerns over cancer. Formaldehyde is also related to allergenicity.

Where does it come from? Imidazolidinyl urea is a synthetic chemical formed by the reaction of allantoin with formaldehyde in the presence of caustic soda, subsequently neutralised with hydrochloric acid. The resulting commercial mixture contains a number of formaldehyde addition products.

What are the health/environmental concerns? Imidazolidinyl urea releases formaldehyde. Formaldehyde is formed in small amounts as a part of normal metabolism. Formaldehyde is a known human carcinogen. It is excret- ed in the urine, mainly as formate. The exact mechanism of toxicity is unknown but it is likely that formaldehyde toxicity occurs when levels inside the cells of the body saturate the main detoxifying enzyme, formaldehyde dehydrogenase, allowing the unmetabolized intact molecules of formaldehyde to exert their negative effects. Formaldehyde forms cross links between proteins and DNA.

Imidazolidinyl urea is also a nitrosating agent which may decompose or react to cause nitrosamine formation. Nitrosamines are produced from secondary amines and amides in the presence of nitrite ions and are believed to be carcinogenic. Urea can also act as a skin sensitizing agent. 40

4. Octinoxate

What is it? Octyl methoxycinnamate (octinoxate) is a carbon-based compound which blocks UVB light.

What is it used for? It is used in lip balms and sunscreens for blocking UVB radiation and as an antimicrobial agent used in cosmetics.

Where does it come from? Octinoxate is a synthetic Carbon-based ester formed from methoxycinnamic acid and (RS)-2-ethylhexanol.

What are the health/environmental concerns? The principal concern is that this synthetic sunscreen agent it has been shown to have endocrine mimicking effects in animals. The reproductive and neurological development of rat offspring were affected4. This may be a cause of concern, as humans are systematically exposed to octinoxate through using sunscreens and other cosmetics.

Octinoxate is also persistent which means our bodies cannot break it down – it has been found in humans. It bioaccumulates which means animals’ bodies cannot remove it quickly enough, so it could also be damaging to wildlife. A recent paper by Axelstad et al states: ‘perinatal OMC-exposure can affect both the reproductive and neurological development of rat offspring, which may be a cause of concern, as humans are systematically exposed to the compound through usage of sunscreens and other cosmetics’.

4 Axelstad, M; Boberg, J; Hougaard, KS; et al. (February 2011). “Effects of pre- and postnatal exposure to the UV-filter Octyl Methoxycinnamate (OMC) on the reproductive, auditory and neurological development of rat offspring”. Toxicology and Applied Pharmacology. 250: 278–290 5. Octocrylene

What is it? A carbon-based compound with an acrylate moiety which absorbs ultra violet light and a fatty alcohol portion which adds oil-like water resistant properties.

What is it used for? A widely used chemical filter which predominantly blocks UVB and some UVA.

Where does it come from? It is an ester formed from the condensation of diphenylcyanoacrylate with 2-ethylhexanol. It forms a viscous liquid.

What are the health/environmental concerns? A widely used UV absorber which has been found in humans and wildlife and is suspected to be persistent. It is a skin irritant in a proportion of people. The principal concern with octocrylene is that it has been shown to be a strong allergen with the potential to cause contact dermatitis in children. In addition adults with a history of photoallergy to the widely used medicine ketoprofen may be more susceptible to photoallergic dermatitis5. More recently a paper by de Groot and Roberts (2014) reviewed octocrylene and reported studies from France, Belgium, Spain and Italy which have reported increases in photo-contact allergies, particularly in those who had previously used topical ketoprofen-containing products.

It seems very likely that octocrylene will be phased out in the not too distant future and substituted with a less allergenic alternative. In the meantime the fact that sensitisation is a ‘one way street’ combined with increasing contact dermatitis rates and the widespread use of ketoprofen means that we should act with precaution and avoid this ingredient.

5 Avenel-Audran et al, 2010 42

6. PEGs: PEG-7; PEG-40; PEG-200; PEG-120

What are they? Polyethylene glycols (PEGs) are polymers of ethylene oxide, of differing repeat sizes.

What are they used for? Polyethylene glycols are used in cosmetics as solvents, thickeners and moisture carriers. They are also used in pharmaceutical preparations. They have many applications in industrial manufacturing.

Where do they come from? They are synthetic chemicals. The different PEGylated compounds are made by conjugation with different compounds. PEG-7 with glyceryl cocoate; PEG-40 with hydrogenated castor oil; PEG 120 with methyl glucose dioleate and PEG-200 with hydrogenated glycerine palmate

What are their health/environmental concerns? They have a high margin of safety for their ability to cause direct toxicity (which means they are relatively safe). However, the main health concerns are about their potential to contain the contaminants ethylene oxide and 1,4 dioxane, both of which cause cancer. Ethylene oxide is classified as a definite human carcinogen (Class 1) and 1,4 dioxane as a possible human carcinogen (Class 2B). Purity is therefore an implicit aspect of their safety. 7. Polyquaternium 7

What is it? Polyquaternium describes a family of polycationic polymers centred about a quaternary ammonium complex

What is it used for? It is used in personal care products as an antistatic agent, film former and hair fixative.

Where does it come from? Polyquaternium 7 is a copolymer of acrylamide and diallyldimethylammonium chloride.

What are the health/environmental concerns? A synthetic polymer used as a film former. The main worry is about contamination with acrylamide, which is a possible human carcinogen and developmental toxicant. There have also been concerns raised in Canada about ecotoxicology, which means toxic effects on life webs found in ecosystems. 44

8. Polysorbate 20

What is it? Polysorbate 20 is a non-ionic surfactant which acts as a detergent

What is it used for? It is used in various domestic cleaning agents, pharmaceutical and scientific application as a detergent and surfactant. In cosmetics it is employed as a surfactant and emulsifier in cleansing agents.

Where does it come from? Synthetic chemical made by the ethoxylation of sorbitan with the subsequent addition of lauric acid.

What are the health/environmental concerns? Under the GHS classification system concerns have been raised over allergic skin reactions from 8 notifications from 156 companies. It has also been associated with serious eye irritation.

A major concern is that during manufacture there can be contamination with the carcinogens ethylene oxide and 1,4-dioxane. Ethylene oxide is classified as a definite human carcinogen (Class 1) and 1,4 dioxane as a possible human carcinogen (Class 2B). 9. Red 17 – Artificial colour 26100

What is it? Red 17 (or Sudan III) is an artificial diazo dye. It is what is termed a straight dye (i.e. it is not a ‘lake’ or a mixture).

What is it used for? To impart a red colouration to a wide variety of cosmetic preparations.

Where does it come from? Sudan III is a synthetic diazo chemical dye which is highly soluble in lipids.

What are the health/environmental concerns? Red 17 is a diazo aromatic dye. It carries concerns about bioaccumulation and persistence in wildlife. There are gaps in available data which raise questions about target organ toxicity, particularly liver and kidneys. There is also some evidence for human carcinogenesis. There are many data gaps.

Red 17 was referred to the EU with three other azo-dye colourants because of the risk that it could cause cancer. This was reviewed by the Scientific Committee on Cosmetics and non-food products (SCCNFP) which agreed that there were concerns that needed to be addressed. The Industry submitted additional information which resulted in a Scientific Committee on Consumer Products (SCCP) report where they opined that they couldn’t perform a risk assessment because of missing data. They need further studies on dermal assimilation and production of the metabolite 4-aminoazobenzene – which is the particular carcinogen under discussion. There are other question marks, including biopersis- tence, organ system toxicity (liver and kidney) and ecotoxicity. 46

10. Retinyl palmitate (Vitamin A palmitate)

What is it? Retinyl is otherwise known as vitamin A1 and is synthesised from beta-carrotene. Retinyl oxidises rapidly under normal conditions and it is stabilised by combining it with palmitic acid to produce the ester retinyl palmitate.

What is it used for? Retinyl palmitate is an antioxidant and is used to protect against skin aging. It is found in anti-aging creams and sunscreen products.

Where does it come from? Retinyl is produced naturally in foods. Retinyl palmitate is synthesised chemically.

What are the health/environmental concerns? There are a number of concerns about the use of retinyl palmitate. The principal concern is over the use of topical applications in pregnant women and the possibility of having too much vitamin A circulating. Vitamin A can be a developmental toxicant if it is not at the correct concentration. It interacts with the expression of the Hox gene which is involved in controlling body segmentation in the embryo. Too much vitamin A can lead to foetal malformations. Yourick et al6 produced some evidence that application of such products to the whole skin could exceed recommended upper daily doses of vitamin A. Hathcock et al7 evaluated vitamin A toxicity and found low dose reproductive effects.

Other concerns include reactive oxygen species production and questions over environmental persistence and toxicity.

6 Yourick JJ, Jung CT, Bronaugh RL. 2008. In vitro and in vivo percutaneous absorption of retinol from cosmetic formulations: significance of the skin reservoir and prediction of systemic absorption. Toxicol Appl Pharmacol 231(1): 117-21 7 Hathcock JN, Hattan DG, Jenkens MY, McDonald JT, Sundaresan PR, Wilkening VL. 1990. Evaluation of vitamin A toxicity. Am J Clin Nutr 52, 183: 202. Produced by the Soil Association

The Soil Association was founded in 1946 by farmers, scientists, doctors and nutritionists to promote the connection between the health of the soil, food, animals, people and the environment. Today the Soil Association is the UK's leading membership charity cam- paigning for healthy, humane and sustainable food, farming and land use. Its Chief Exec- utive is Helen Browning, and Chair of Trustees is Dennis Overton.

Soil Association Certification is a wholly owned subsidiary which certifies over 70% of all organic products sold in the UK. Certifying organic food and farming since 1973, and more recently, organic textiles, health and beauty products, the team has built up exten- sive practical experience and provides unrivalled support before, during and after certification. It also audits other schemes within catering and forestry, including the Food for Life Catering Mark, and the FSC and PEFC forestry standards internationally, delivering assurances of quality and provenance that industry and consumers can trust. Its Chief Executive is Martin Sawyer and its independent board is chaired by Nick Buckland. To find out more visit www.soilassociation.org

Supported by Neal’s Yard Remedies